MiCA in Lithuania: Pre-Implementation Measures and Requirements

With the upcoming implementation of the Markets in Crypto Assets (MiCA) regulation across the EU, Lithuania is taking proactive steps to prepare its crypto-asset service providers (CASPs) for the new compliance landscape. The MiCA regulation, effective from December 2024, introduces a comprehensive framework for regulating the crypto industry, focusing on consumer protection, anti-money laundering (AML) measures, and financial stability.

Lithuanian authorities, including the Ministry of Finance, the Bank of Lithuania, and the Financial Crime Investigation Service (FCIS), are working diligently to ensure a smooth transition. Although MiCA allows for a transitional period until 2026, Lithuania has opted for an accelerated timeline, requiring CASPs to be fully compliant by mid-2025.

In preparation for MiCA, several pre-implementation measures have already been enacted. One key requirement was that CASPs should have provided proof of meeting the minimum capital threshold of €125,000 by August 2024. This move was part of a broader effort to increase transparency and strengthen oversight within the sector.

While many companies have complied, the lack of specific guidance on what constitutes sufficient proof of capital has caused some confusion. Firms have submitted a range of documentation based on their interpretations of the requirements. Although the evaluation of these submissions is still ongoing, it is already evident that a lack of comprehensive financial statements may increase the risk of non-compliance.

Therefore, even though the regulatory framework is still evolving, CASPs are encouraged to consult proactively with Lithuanian authorities and ensure that their financial records are always up-to-date. This will better position them to demonstrate compliance with capital adequacy requirements whenever necessary.

If you need assistance with managing the financial records of your CASP, feel free to contact us at hello@numberminded.com.